Signature of the Referring Physician Required

December 15, 2010

PDM sponsored a call with Jane Pine Wood on Monday, December 13, 2010 at 4:00pm EST. The primary purpose of the call was to address the impending need for a signature of the referring physician on AP and CP requisitions.

Ms. Pine Wood stated that Medicare’s rule for AP (diagnostic services) is that a physician’s signature is required on written orders for AP service.

The Centers for Medicare & Medicaid Services (CMS) will accept the following as a signed requisition from your referring physician:

  • Written order and signature on an inpatient chart
  • Electronic order with an electronic signature
  • Telephone order properly documented by both parties

For labs dealing in high volumes from physicians, Jane Pine Wood recommends a standing order from referring physicians be signed on an annual basis and kept on file in case of a CMS audit.

When CMS publishes the Manual Provisions in January, the speculation is at this time CMS will require the referring physician’s signature for CP. The reason given is CMS is trying to tighten up their reimbursement procedures to assure that what is being billed is medically necessary and being performed.

By design of hospital procedures, CMS is comfortable this process is being followed and is more concerned at this time with outreach care. They see the signature from the referring physician as an indication it is medically necessary.

As a rule of thumb, anything with a cpt code and is recognized on the Medicare fee schedule will require a referring physician’s signature.

Note that at this time, proof of signature is not required to receive payment from CMS, but is highly recommended to have on file in case of an audit.

CMS will publish their update provisions in January, so be aware all is subject to change.

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